Effective Date: February 16, 2020
[Last Version as of September 5, 2019, is available here]
Display.io Ltd. (together with its subsidiaries, affiliates, officers and directors, as applicable (each individually, or collectively “Display.io”, “Company”, “we” or “us”) is a global mobile ad-tech company that provides developers, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering advertising to individuals (“user(s)”) who download, use or otherwise interact with an app developers’ app, site or our services (“Digital Assets”), as defined below (collectively, “Advertising Service(s)“).
- Information we collect from visitors of our website available at: https://www.display.io (“Site”) and our Business Partners who register to our Services through our Site.
- Information we collect from users who interact with our Business Partners’ Digital Assets which are using our advertising platform.
- Our lawful basis for data processing (as required under the EU General Data Protection Regulation (“GDPR”), and applicable for European Economic Area ("EEA") residents).
- Types of data we collect and why (the purpose)
- How we collect data and categories of the data source
- What are cookies and how we use them
- Sharing data with third parties
- Our data retention policy (meaning, for how long and how we retain personal information, and when will we delete the data we collect)
- How we protect data
- User choices and controls (including opt out information)
- User rights
- How do we transfer data internationally
- Children Privacy Online
- “Do Not Track” disclosure
- Special Jurisdictions (if you are a California resident, you should not skip this section)
- How to contact us
If you are a resident of any member state of the EU, EEA or UK, this section applies to you.
As required under GDPR, the lawful basis for our data collection and processing is as follows:
- Where a Business Partner uses our Services, we process the Business Partner’s Personal Data in order to perform our contract with the Business Partner.
- Certain Online Identifiers, such as third party cookies or mobile advertising identifiers we use, are based on consent, when such usage involves any aspect of personalization; and based on legitimate interest when we use them for functionality abilities, compatibility, run statistics, aggregations, analytics and measurements.
- When we use IP address for fraud detection and prevention, or, when we use it to detect country and language, we are based on legitimate interest.
- For direct marketing of Business Partners, we will process such data under our legitimate interest.
Display.io acts as a Processor of certain Personal Data, as defined under the GDPR, such as the data processed from our users using our Business Partners’ Digital Assets. Display.io is also a Controller of certain Personal Data, such as of our Business Partner’s registration data, or if individuals contact us via our Site.
Types of Data We Collect
If you are a visitor of our Site, Business Partner or a user of our Business Partner’s Digital Assets which use our Advertising Services, Display.io collect several types of data, which can be mainly classified as follows:
- “Non-Personal Data”: non-identifiable or non-personal information which is not identifiable to or associated with a specific individual. This category also includes any deidentified data (defined under the California Consumer Privacy Act, “CCPA”), or irreversibly anonymous data.
- “Personal Data”: individually identifiable information, namely information that identifies an individual or may with reasonable effort lead to identifying an individual.
In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
For your convenience, we have arranged the types of data we collect according to your interaction with us, meaning, the first table below will detail the data we collect from visitors of our Site including our Business Partners who register to our Advertising Services, and the second table will detail the data we collect from users who interact with our Advertising Services (e.g., a user who have downloaded our Business Partner’s app which serves ads through our Advertising Services). The tables below will also explain the purpose of the data collection and how we use each type of data.
Data we collect from Business Partners and visitors to our Site:
|Type of Data||How Do We Use It?|
|Business Partners’ Registration Data – if you are or wish to be our Business Partner, when you create a developer account with us, you will be required to provide us with certain information such as: full name, email address and company name. Further, during the registration process you will be required to create a username and password.||We will use this data for the purpose of performing our contract with you, meaning provide the Advertising Services, and designate your account. Your contact details will be used in order to send you needed information related to our Advertising Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Advertising Services, send applicable invoices, , and similar notifications) and additional occasional communications and updates related to the Advertising Services, as well as provide you with tips related to our Advertising Service, promotional and marketing emails regarding Display.io’s tools and services. We will may also use the information in order to verify your identity.|
|Contact Information - in the event you contact us for support, feedback, meeting set up or other inquiries, by sending us an email or by other means of communications, including any online form available on our Site, you will be requested to provide us your contact details such as name and email address.||We will use this data for the purpose of performing our contract with you, meaning provide the Advertising Services, and designate your account, or, as applicable, to investigate and address the request for which purpose you have reached out to us. We may also use the information in order to verify your identity.|
|Newsletter Subscription - if you voluntarily subscribe to our Newsletter through the Site (or otherwise agree to receive our updates and content), you will be requested to provide us with email address and name. You can unsubscribe at any time using the unsubscribe option within the body of the applicable email or rather by contacting us (as detailed below).||We will use this data in order to send you the information related to our Advertising Services and to keep you up to date regarding new services, as well as provide you with tips related to our Advertising Service, promotional and marketing emails (offers, events and discounts).|
|IP address and Technical Non-Personal Data - when you access our Site or interact with our Services, we will collect certain data such as IP address as well as technical Non-Personal Data (such as viewing and usage analytics that relates to your interaction with the Site, the amount of time you spend viewing certain portions of the Site, etc.).||We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our Site and the way in which we offer it; (ii) enhancing your experience; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow; and (iv) protect the security of the Site, as well as our and third parties’ rights (subject to applicable law requirements).
If we use third party cookies on our Site we will obtain your consent.
Data we collect from users who interact with our Business Partners’ Digital Assets (meaning user who download our Business Partner’ mobile app which integrates our Advertising Services technology:
|Type of Data||How Do We Use It?|
The Display.io Advertising Service technology (the “SDK”) is a piece of software that is integrated into various apps and allows them to provide users with advertisements. We collect through the SDK certain data related to the device and use of the app including device information needed in order to operate the app, as well as Advertising ID that is generated by the mobile operating system for purposes of serving ads, IP address that helps us understanding the language and location, and sometimes helps us with fraud detection and understanding if it is a bot or a human that view an ad.
Demographic and Online Data:
Subject to the jurisdictions of your residency, some additional steps may be involved, as detailed under the “Special Jurisdictions” section below.
This data will be used to: (i) enable the delivery of ads, including personalized ads and monitor the frequency of ads served; (ii) reporting and calculating payments with regards to our Business Partners’ use of our Advertising Services; (iii) detect fraud and other security issues related to our Advertising Services and the access to them; (iv) our internal business needs such as Internal statistics and in order to further improve our Advertising Services, products and technologies (e.g., to control the number ads served to you while you use our Business Partner’s mobile app).
How We Collect Data and category of the data source
We may collect the data detailed above in two different ways:
- Data you provide to us. When you voluntarily provide us with such data – meaning, for example, if you are Business Partner and you register to our Advertising Services and create an account through our Site, or if you are a visitor of our Site and you contact us.
What are cookies and how we use them
When you visit Display.io Site, we may use anonymous online tracking technologies known as “cookies” and similar technologies (also known as web beacons and pixel tags). Cookies are small text files that are placed on your hard drive by a web server when you access our Site or Services online.
The cookies can be used for various purposes, such as to facilitate the use of the Site, to collect statistical information or customize the Site and our services offered therein. If you wish to block or refuse the cookies, you can do so by modifying the settings in your browser and by following the necessary browser’s instructions to disable receipt of cookies – please review the “User Choices and Controls” section below for helpful information. However, bear in mind that disabling cookies may complicate or even prevent certain features of the Site and our services and your online experience may be limited. You can find more information about cookies at www.allaboutcookies.org.
|Google Analytics||Analytic purposes||https://www.google.com/policies/privacy/partners
|Umbraco||Enable the use of the Site and service||https://umbraco.com/about-us/privacy|
|Intercom||Enhance the use of the Site||https://www.intercom.com/terms-and-policies#cookie-policy
Sharing Data with Third Parties
Generally speaking, we do not share any Personal Data collected from you with third parties or any of our partners except in the following events, and solely to the extent needed:
- If the Company is required, or reasonably believes that it is required by law or law enforcement agencies to share or disclose your information;
- In any case of dispute, or legal proceeding of any kind between you and the Company or between you and other users with respect to, or in relation with the Site or Advertising Services;
- We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf, for example for security, fraud detection, server and data storage providers, etc. (among others, as detailed in the “Cookies” section above);
- We may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
- We may share certain identifiers and demographic data (as detailed above), including Advertising IDs and IP addresses collected by us (as detailed above) with our advertising Business Partners and service providers, for the purpose of operating and improving our business, providing the Site or Advertising Services, as well as to detect fraud, security or technical issues in connection with the Site or Advertising Services. Sharing of Personal Data for personalization purposes is performed according to the data regulation of the jurisdiction in which our Advertising Services are enabled..
Data Retention Policy
The table below details our data retention practices – meaning , when will we delete data we collect and process:
|Data Sets||Retention Period|
|Online Identifiers / demographics||Deleted immediately following the completion of use according to the purpose. Save for exemptions, those are being deleted within 7 days.|
|Contact Details||Deleted Immediately following the completion of your request, unless applicable regulation requires otherwise|
|Business Partner Data||According to applicable laws.|
|Technical Information||For as long as needed to provide and improve our Advertising Services.|
Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
How we Protect Data
Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
User Choices and Controls
You may opt-out of the personalized use of your data collection and sharing process related to our Site or Advertising Service, as detailed below.
Options to opt out:
- Mobile opt-out
If you use an Android device please follow this link for instructions: https://support.google.com/ads/answer/2662922
If you use an iOS device please follow this link for instructions: https://support.apple.com/en-il/HT205223.
- Website opt-out
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Chrome; Firefox; Opera; Internet Explorer; Safari; Edge.
- California Residents opt-out rights
Certain data sharing practices we use may be qualified as “data selling” according to the California Consumer Privacy Act (CCPA). If you are (1) a user of our Business Partners’ apps, and (2) California resident, and (3) the app you are using engaged with delivering of personalized ads or content, you will have the right to opt-out via the app’s settings, as will be provided and explained to you by the app owner. In which case, where you opt-out from data selling, we will receive your opt-out request from our Business Partner to further execute as required by the CCPA.
- Email Marketing opt-out
- Industry Standards and specific opt-out options
You may opt-out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website - NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website - DAA opt-out page. If you wish to opt-out of interest-based advertising, you may click here.
Business Partners opt-out
You may also contact us at: firstname.lastname@example.org and we will be happy to assist you with your opt-out request. Note that once you opt out, part of the Site or Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
Please be noted, when you opt-out as described in this section, you opt out of the personalized use of your personal information. It doesn’t mean you will no longer receive ads from us or our Business Partners, it only means that these ads are not personalized to your preferences.
Data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; right to access your Personal Data; right of rectification; the right to erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to processing of your Personal Data; data portability; the right to file a complaint to a supervisory authority (in the event you are an EEA resident); and, the right to withdraw consent. If you are a California resident, check the information about your user rights under the “Special Jurisdictions” section below.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, where and if they are applicable, including the right to complain to the supervisory authority, when applicable (EEA residents). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
International Transfer of Data
Do Not Track Disclosure
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com.
Children Privacy Online
When applicable, Company implements measures to comply with applicable Children Online Privacy regulation, including the US Children’s Online Privacy Protection Act (“COPPA”). If we become knowledgeable of user that is considered a Child under applicable laws, we make sure to not process their personal data and take steps to delete such data if existed.
If you become aware or have any reason to believe that a Child has shared any Personal Information with us, please contact us at: email@example.com.
Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, these additional terms and conditions apply to you.
Certain data sharing practices we use may be qualified as “data selling” according to the CCPA. In such cases, you will have the right to opt-out via the app’s settings, as will be provided and explained to you by the app owner. In which case, where you opt-out from data selling, we will receive your opt-out request from our Business Partner to further execute as required by the CCPA.
(b) We provide the following additional disclosures related to the collection, use, and disclosure of personal information under the CCPA:
From Visitors of our Site or users of our Business Partners’ digital assets:
- Online Anonymous Identifiers. Such as cookie ID, Advertising ID or IP Address;
- Internet or other electronic network or device information. Operating system type and version, browser type and version, and IP address;
- Analytics. Such as interaction with our Site or Advertising Services;
From our Business Partners:
- Commercial and billing information. Such as your name, email address, role, company’s name. In some cases this category will also include payment method and related information;
- Categories of Personal Information Disclosed. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: online anonymous identifiers (to provide the Advertising Services, for analytics and fraud detection and prevention); personal identifiers of our Business Partners, with customer management tools and platforms, (for communication, updates, support, storage, validation and security purposes); commercial and billing information (payment processing, billing and invoicing), Internet or other web information (analytics, statistics, marketing, offering).
- Sale of Personal Information. In the preceding 12 months, the only activity that might be qualified as “sale of personal information” is sharing your online and network identifiers with our advertising partners for personalized advertising purposes. Avanquest does not sell the personal information of our users.
- Your Consumer Rights. If you reside in California, you have the right to request access to the specific pieces of personal information we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, and the categories of personal information we have disclosed about you in the preceding 12 months. As a California consumer, you also have the right to (i) request deletion of your personal information (subject to certain exceptions), (ii) opt-out of sales of personal information (where and in case existed), and (iii) receive equal service and price and not be discriminated against even if you exercise any of your other CCPA rights.
California consumers may make requests to exercise their rights by using the following methods:
- Other rights:
Note that in order to fulfill your request, we may need you to provide certain information to verify your identity. You can also designate an authorized agent to exercise these rights on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.
Data Protection Officer
Please be sure to include your information in any correspondence to us and to title your communication with the relevant request, so that we can respond to your inquiry in a timely manner.
Comments and Questions
You can also contact us via email at: firstname.lastname@example.org.